IR 05000416/2011008

NRC Temporary Instruction 2515/183 Inspection Report 05000416/2011008

ML11133A249
Person / Time
Site:	Grand Gulf
Issue date:	05/13/2011
From:	Vincent Gaddy NRC/RGN-IV/DRP/RPB-C
To:	Mike Perito Entergy Operations
References
IR-11-008
Download: ML11133A249 (22)

Text

UNIT ED STAT ES NU C LE AR RE G UL AT O RY C O M M I S S I O N May 13, 2011

SUBJECT:

GRAND GULF NUCLEAR STATION - NRC TEMPORARY INSTRUCTION 2515/183 INSPECTION REPORT 05000416/2011008

Dear Mr. Perito:

On April 29, 2011, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at your Grand Gulf Nuclear Station, using Temporary Instruction 2515/183, "Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event." The enclosed inspection report documents the inspection results which were discussed on April 29, 2011, with Mr. Perito, Vice President Operations, and other members of your staff.

The objective of this inspection was to assess the adequacy of actions taken at the Grand Gulf Nuclear Station in response to the Fukushima Daiichi Nuclear Station fuel damage event. The results from this inspection, along with the results from similar inspections at other operating commercial nuclear plants in the United States, will be used to evaluate the United States nuclear industrys readiness to respond to a similar event. These results will also help the NRC to determine if additional regulatory actions are warranted.

All of the potential issues and observations identified by this inspection are contained in this report. The NRCs Reactor Oversight Process will further evaluate any issues to determine if they are regulatory findings or violations. Any resulting findings or violations will be documented by the NRC in a separate report. You are not required to respond to this letter.

In accordance with 10 CFR 2.390 of the NRCs "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of NRCs document system (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Entergy Operations, Inc. -2-

Sincerely,

/RA/

Vincent G. Gaddy, Chief Project Branch C Division of Reactor Projects Docket: 50-416 License: NPF-29

Enclosure:

Inspection Report 05000416/2011008 w/Attachment: Supplemental Information

REGION IV==

Docket: 05000416 License: NPF-29 Report: 05000416/2011008 Licensee: Entergy Operations, Inc.

Facility: Grand Gulf Nuclear Station Location: 7003 Baldhill Road Port Gibson, MS 39150 Dates: March 23 through April 29, 2011 Inspectors: R. Smith, Senior Resident Inspector R. Kumana, Acting Resident Inspector A. Fairbanks, Acting Resident Inspector Approved by: Vincent G. Gaddy, Chief, Project Branch C Division of Reactor Projects-1- Enclosure

SUMMARY OF FINDINGS

IR 05000416/2011008, 03/23/2011 - 04/29/2011; Grand Gulf Nuclear Station Temporary

Instruction 2515/183 - Followup to the Fukushima Daiichi Nuclear Station Fuel Damage Event.

This report covers an announced temporary instruction inspection. The inspection was conducted by resident and Region IV inspectors. The NRCs program for overseeing the safe operation of commercial nuclear power reactors is described in NUREG-1649, "Reactor Oversight Process," Revision 4, dated December 2006.

INSPECTION SCOPE

The intent of the temporary instruction is to be a high-level look at the industrys preparedness for events that may exceed the design basis for a plant. The focus of the temporary instruction was on

(1) assessing the licensees capability to mitigate conditions that result from beyond design basis events, typically bounded by security threats;

(2) assessing the licensees capability to mitigate station blackout conditions;

(3) assessing the licensees capability to mitigate internal and external flooding events required by station design; and

(4) assessing the thoroughness of the licensees walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site. If necessary, a more specific followup inspection will be performed at a later date.

INSPECTION RESULTS

The following table documents the NRC inspection at Grand Gulf Nuclear Station performed in accordance with Temporary Instruction 2515/183. The numbering system in the table corresponds to the inspection items in the temporary instruction.

03.01 Assess the licensees capability to mitigate conditions that result from beyond design basis events, typically bounded by security threats, committed to as part of NRC Security Order Section B.5.b issued February 25, 2002, and severe accident management guidelines and as required by Title 10 CFR 50.54(hh). Use Inspection Procedure 71111.05T, "Fire Protection (Triennial)," Section 02.03 and 03.03 as a guideline. If Inspection Procedure 71111.05T was recently performed at the facility, the inspector should review the inspection results and findings to identify any other potential areas of inspection. Particular emphasis should be placed on strategies related to the spent fuel pool. The inspection should include, but not be limited to, an assessment of any licensee actions to:

Licensee Action Describe what the licensee did to test or inspect equipment.

a. Verify through test or The licensee performed a comprehensive review of all procedures used to mitigate conditions inspection that that result from beyond design basis events. The licensee verified through testing that the fire equipment is available pumper truck used in various B.5.b strategies can produce the required flows to accomplish and functional. Active these strategies. They also tested the portable generator used to supply temporary power to equipment shall be one division of hydrogen igniters during B.5.b events to verify that it was functional and able to tested and passive accomplish its required action. Additionally, they tested the digital tachometer used for equipment shall be operating reactor core isolation cooling with no alternating or direct current.

walked down and inspected. It is not expected that Describe inspector actions taken to confirm equipment readiness (e.g., observed a test, permanently installed reviewed test results, discussed actions, reviewed records, etc.).

equipment that is tested under an existing regulatory The inspectors reviewed the results for the following tests of equipment used in B.5.b.

testing program be strategies:

retested.

fire pumper truck performed on March 18, 2011; This review should be portable generator used to supply temporary power to one division of hydrogen igniters done for a reasonable performed on March 16, 2011; and sample of mitigating strategies/equipment.

digital tachometer performed on March 22, 2011 The inspectors independently walked down the passive equipment and verified the contents of the licensees emergency lockers were in accordance with station procedures. The inspectors

also discussed with plant and licensed operators how the active and passive equipment is tested, maintained, stored, and trained on. Additionally, the inspectors walked down several of the procedures with a plant operator to ensure familiarity with the operation of the equipment, storage locations, and equipment location.

Discuss general results including corrective actions by licensee.

The licensee identified numerous procedure enhancements, moved the hazmat trailer to a new location, discovered some equipment that, though in the proper location, was not on the inventory check list, and found that two wrenches on the inventory check list were not in place.

The licensee entered these deficiencies in the corrective action program and corrected them by revising procedures or inventories and ensuring all required tools were in place. The licensee noted that the digital tachometer for operation of reactor core isolation cooling had a dead battery. The licensee replaced the battery in the tachometer and verified it could perform its function. The licensee entered this issue into the corrective action program with an action to change procedures to perform periodic inventory of the tachometer, including battery checks.

During the inspector walkdowns, the need for additional procedure enhancements, some operator familiarity issues, and the lack of staged procedures in some locations were noted.

The licensee entered these issues into the corrective action program and has taken or will take actions to correct the issues identified by the inspectors. None of the issues identified by the inspectors would have prevented accomplishment of the actions in the licensees strategies.

Licensee Action Describe the licensees actions to verify that procedures are in place and can be executed (e.g.,

walkdowns, demonstrations, tests, etc.)

b. Verify through The licensee performed walkdowns of all of procedures used to mitigate conditions that result walkdowns or from beyond design basis events. The licensee conducted tabletop exercises for the major demonstration that event response guidelines, severe accident procedures, and system operating instructions; the procedures to licensee also performed a tabletop exercise with the local fire department. Some of the implement the equipment is used for other activities, and the licensee has verified through those other strategies associated activities that the systems work and that operators are familiar with how to operate the with B.5.b and equipment.

10 CFR 50.54(hh) are Describe inspector actions and the sample strategies reviewed. Assess whether procedures in place and are were in place and could be used as intended.

executable. Licensees may choose not to connect or operate The inspectors reviewed all the severe accident procedures and guidelines to ensure that the permanently installed appropriate equipment, training, staging, and timelines could be followed. The inspectors equipment during this determined that the licensees procedures were in place as required by the current inventory, verification.

that operators had been trained during initial training on these procedures, and that the This review should be procedures could be implemented as intended. The inspectors walked down several strategies done for a reasonable with plant operators to ensure that the operators knew where the equipment was located, how sample of mitigating to operate the equipment, and the ease of use of the equipment.

strategies/equipment.

Discuss general results including corrective actions by licensee.

The licensees review of its procedures revealed that some procedural revisions were required.

The licensee entered these issues in the corrective action program and corrected them by revising procedures. During the inspector walkdowns, the need for additional procedure enhancements, some operator familiarity issues, and the lack of staged procedures in some locations were noted. The licensee entered these issues into the corrective action program and have taken or will take actions to correct the issues identified by the inspectors. None of the issues identified by the inspectors would have prevented accomplishment of the actions in the licensees strategies.

Licensee Action Describe the licensees actions and conclusions regarding training and qualifications of operators and support staff.

c. Verify the training and The licensee performed a review of the required personnel qualifications and training programs.

qualifications of Nonlicensed plant operators receive initial training on these severe accident procedures operators and the through classroom presentation and walkdowns with instructors, which is required prior to initial support staff needed to watch standing. Continuing training for nonlicensed plant operators is accounted for in the implement the plant operator requalification three year plan, and includes classroom sessions and procedures and work walkthroughs. Licensed operators receive initial training on these severe accident procedures

instructions are current along with all emergency operating and off-normal event procedures as part of initial licensed for activities related to operator qualification. Continuing training for licensed operators is performed in the licensed B.5.b and severe operator requalification plan and emergency planning continuation training. The emergency accident management response organization training requirements are governed by a procedure in the emergency guidelines as required preparedness training program and personnel on the emergency response roster must by 10 CFR 50.54 (hh).

complete training/requalification every year. Licensed operators do not currently receive continuing training on B.5.b actions, but the licensee will be reviewing this during its next operations training review group meeting.

Describe inspector actions and the sample strategies reviewed to assess training and qualifications of operators and support staff.

The inspectors reviewed training records of all nonlicensed plant operators, licensed plant operators, and all emergency response roster personnel to ensure that they were still within their training window. The inspectors walked down and discussed several strategies with plant and licensed operators to ensure that the operators knew where the equipment was located, knew how to operate the equipment, and could complete the procedures as written.

Discuss general results including corrective actions by licensee.

The licensee review of operator qualifications revealed that 12 operators (six senior reactor operators, one reactor operator and five nonlicensed operators) had received the initial B.5.b training, but had not received training for changes in the training curriculum from their initial training. The licensee entered this issue into the corrective action program and conducted the required training for the operators.

During the inspectors walkdowns, it was noted some operators did not locate equipment in a timely manner. The licensee entered this issue into the corrective action program and have taken or will take actions to correct the issue identified by the inspectors. The issue identified by the inspectors would not have prevented accomplishment of the actions in the licensees strategies.

Licensee Action Describe the licensees actions and conclusions regarding applicable agreements and contracts are in place.

d. Verify that any The licensee reviewed Letters of Agreement with federal, state and local entities. The licensee applicable agreements determined that the agreements were current and that required offsite equipment for response and contracts are in was available. This review was accomplished in March 2011.

place and are capable of meeting the conditions needed to For a sample of mitigating strategies involving contracts or agreements with offsite entities, mitigate the describe inspector actions to confirm agreements and contracts are in place and current consequences of these (e.g., confirm that offsite fire assistance agreement is in place and current).

events.

This review should be The inspectors reviewed all Letters of Agreement to ensure that they were current. The done for a reasonable inspectors reviewed the licensee procedure which requires an annual review of agreement sample of mitigating letters.

strategies/equipment.

Discuss general results including corrective actions by licensee.

The licensee determined that one memorandum of understanding with Hydra of Birmingham, Alabama, for fire water services had not been renewed after 2008, and the licensee entered this issue into the corrective action program. In its investigation, the licensee determined that the memorandum of understanding was no longer required because the condition that necessitated additional fire water no longer existed.

Licensee Action Document the corrective action report number and briefly summarize problems noted by the licensee that have significant potential to prevent the success of any existing mitigating strategy.

e. Review any open The licensee has captured procedural enhancements, additional required locations of corrective action procedures in the field, incomplete inventory checklists, missing items in emergency lockers, and documents to assess other miscellaneous items in the corrective action program.

problems with The inspectors reviewed the associated corrective action reports and verified that none of the mitigating strategy identified gaps or deficiencies would have significant potential to prevent the success of any implementation existing mitigating strategy.

identified by the licensee. Assess the impact of the problem on the mitigating capability and the remaining capability that is not impacted.

03.02 Assess the licensees capability to mitigate station blackout conditions, as required by 10 CFR 50.63, "Loss of All Alternating Current Power," and station design, is functional and valid. Refer to Temporary Instruction 2515/120, "Inspection of Implementation of Station Blackout Rule Multi-Plant Action Item A-22" as a guideline. It is not intended that Temporary Instruction 2515/120 be completely reinspected. The inspection should include, but not be limited to, an assessment of any licensee actions to:

Licensee Action Describe the licensees actions to verify the adequacy of equipment needed to mitigate a station blackout event.

a. Verify through The licensee reviewed 10 CFR 50.63, Regulatory Guide 1.155, NUMARC 87-00, the Updated walkdowns and Final Safety Analysis Report, and the NRCs Safety Evaluation Report in response to the inspection that all Updated Final Safety Analysis Report, to ensure the basis for actions for a station blackout.

required materials are The licensee uses a coping strategy for the required station blackout coping duration of adequate and properly 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The licensee verified that required equipment for station blackout recovery actions staged, tested, and was adequate and properly staged.

maintained.

Describe inspector actions to verify equipment is available and useable.

The inspectors reviewed the licensees Updated Final Safety Analysis Report to understand the implementation and required equipment for station blackout and coping strategies. On April 20-21, 2011, the inspectors observed the most recent 24-hour surveillance run of the Division 3 diesel generator that included a fast restart. The inspectors observed a safety related battery surveillance on March 29, 2011. Additionally, the inspectors searched through the corrective action program database for items that could impact the operability of the station batteries and standby diesel generators.

Discuss general results including corrective actions by licensee.

The licensee identified that several keys required for station blackout procedures were not controlled by its key control procedure. One required key was not included in the shift managers key locker. In addition, the licensee did not have inventories in process for nitrogen bottles that are also required. The licensee entered these issues into the corrective action program, immediately replaced the key, and is revising the inventory procedure to ensure the required items are included. During the inspectors reviews, they noted that there was no updated index for the shift mangers key locker to identify where the new required keys were located in the locker. The licensee corrected the index to identify the location of the newly added keys.

Licensee Action Describe the licensees actions to verify the capability to mitigate a station blackout event.

b. Demonstrate through The licensee verified that Off-Normal Event Procedure 05-1-02-I-4, "Loss of AC Power," was walkdowns that executable. This verification involved performing the procedure in the simulator, conducting a procedures for walkdown of the procedure steps, and performing a "tabletop" discussion with operators.

response to a station Describe inspector actions to assess whether procedures were in place and could be used as blackout are intended.

executable.

The inspectors walked down the station blackout procedure with plant operators, both in the control room and the plant, to ensure that the operators knew where the equipment was located and how to operate the equipment and to verify the procedure worked as written. The walkdown included locations of supplemental equipment.

Discuss general results including corrective actions by licensee.

The licensee identified one step in the procedure that would not be executable as written, in addition to the issue with keys identified in Section 03.03.a. These deficiencies were entered into the corrective action program. In addition, several enhancements to the procedure were noted, and they will be evaluated for inclusion into future revisions. During the inspectors walkdowns and reviews, they noted that one operator was not familiar with the location of one valve. Inspectors also noted that some sections of the procedure could be enhanced. The licensee entered these issues into their corrective action program. None of these conditions would have prevented implementation of the procedure.

03.03 Assess the licensees capability to mitigate internal and external flooding events required by station design.

Refer to Inspection Procedure 71111.01, "Adverse Weather Protection," Section 02.04, "Evaluate Readiness to Cope with External Flooding," as a guideline. The inspection should include, but not be limited to, an assessment of any licensee actions to verify thorough walkdowns and inspections that all required materials and equipment are adequate and properly staged. These walkdowns and inspections shall include verification that accessible doors, barriers, and penetration seals are functional.

Licensee Action Describe the licensees actions to verify the capability to mitigate existing design basis flooding events.

a. Verify thorough The licensee reviewed the equipment and penetrations required to mitigate internal and walkdowns and external flooding events. The licensee inspected the probable maximum precipitation seals and inspection that all watertight doors.

required materials are adequate and properly staged, tested, and maintained.

Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.

Inspectors verified that the plant grade is 132.5 feet above mean sea level and that the maximum expected flood height from the Mississippi River is about 103 feet above mean sea level. Therefore, floodwaters from the Mississippi River are not expected to impact the plant.

Inspectors toured various levels of the enclosure building, auxiliary building, and control building roofs and verified that the roofs were free of debris that could potentially impact roof drains. Inspectors also verified that the drains had covers.

Inspectors performed walkdowns of the high pressure core spray, low pressure core spray pump, and residual heat removal C rooms to verify that the integrity of piping, door seals, and electrical seal penetrations was maintained. Inspectors did not find any issues of concern.

Inspectors also reviewed the most recent door seal and penetration inspections and independently inspected the probable maximum precipitation seals.

Discuss general results including corrective actions by licensee.

The licensee identified two probable maximum precipitation seals that were degraded. The licensee entered the degraded seals into their corrective action program and ensured that sandbags were located in the vicinity of the doors as a compensatory measure until the seals could be repaired. The licensee has repaired all probable maximum precipitation seals. The licensee noted that one watertight door had not been inspected since 2008. The licensee entered this into the corrective action program and will inspect and test the seal during the week of May 2, 2011.

While independently inspecting the probable maximum precipitation seals, inspectors identified doors with degraded seals that the licensee failed to identify during its most recent inspection.

The licensee put the degraded seals into the corrective action program and ensured that sandbags were located in the vicinity of the doors as a compensatory measure until the seals could be replaced. Additionally, the inspectors will be evaluating the issue with probable maximum precipitation seals during the second quarter integrated inspection report.

The inspectors will review the results of the watertight door inspection and tests and document any deficiencies in the second quarter integrated inspection report. During the inspectors review of roof drains, they noted two drains without covers. These had already been entered into the licensees corrective action program.

03.04 Assess the thoroughness of the licensees walkdowns and inspections of important equipment needed to mitigate fire and flood events to identify the potential that the equipments function could be lost during seismic events possible for the site. Assess the licensees development of any new mitigating strategies for identified vulnerabilities (e.g., entered it in to the corrective action program and any immediate actions taken). As a minimum, the licensee should have performed walkdowns and inspections of important equipment (permanent and temporary)such as storage tanks, plant water intake structures, and fire and flood response equipment; and developed mitigating strategies to cope with the loss of that important function. Use Inspection Procedure 71111.21, "Component Design Basis Inspection," Appendix 3, "Component Walkdown Considerations," as a guideline to assess the thoroughness of the licensees walkdowns and inspections.

Licensee Action Describe the licensees actions to assess the potential impact of seismic events on the availability of equipment used in fire and flooding mitigation strategies.

a. Verify through Licensee actions included identifying the equipment that would be used for mitigation of fire and walkdowns that all flooding events, and determining if the equipment was seismically qualified. Fire protection required materials are systems were evaluated for the ability to withstand seismic events. All of the flood mitigating adequate and properly seals and penetrations were walked down to the extent allowable. The licensee inspected roof staged, tested, and drainage for ponding concerns. The licensee also reviewed the Letters of Agreement with state maintained.

and local entities to verify which agreements were still in place.

Describe inspector actions to verify equipment is available and useable. Assess whether procedures were in place and could be used as intended.

The inspectors reviewed the Updated Final Safety Analysis Report to determine the maximum flood level for the site and the required equipment to combat floods. The inspectors also reviewed the Updated Final Safety Analysis Report sections covering fire protection systems to determine the license requirements. The inspectors reviewed the licensees fire protection program and flooding mitigation procedures, including natural and destructive phenomena procedures. The inspectors walked down the licensees equipment to ensure it was available and usable and to ensure that the procedures could be accomplished as written. This included walking down contingency response equipment, all external watertight doors, the walls of all external buildings for signs of degradation, and the fire protection water system pumps. The licensee also performed an aggregate review of all the vulnerabilities identified to determine if any cumulative effects presented additional vulnerabilities.

Discuss general results including corrective actions by licensee. Briefly summarize any new mitigating strategies identified by the licensee as a result of their reviews.

The licensee determined that all fire protection systems were designed and installed in accordance with the National Fire Protection Association Codes. Consequently, none of the fire protection systems are seismically qualified, with the exception of portions that are in seismically qualified buildings. The licensee determined that the nonseismically qualified fire protection systems were of a robust design that would likely survive a seismic event. The licensee determined that the emergency core cooling systems pump room flood switches were not seismically qualified and initiated a corrective action to evaluate their functionality after a safe-shutdown earthquake. It also determined that a section of the fire ring header passing through the Unit 2 turbine building is not seismically qualified. The licensee is evaluating whether this section of piping would be functional following a safe shutdown earthquake.

Mitigating actions for this condition need to be developed. The licensee also determined that the storage building where the fire pumper truck is located has ductwork hanging over the parked position of the truck. Mitigating actions, which may involve additional support for the ductwork or potentially relocating the ductwork, need to be developed. Additionally, the licensee determined the fire pumper truck and the portable generator used to supply temporary power to one division of hydrogen igniters are located in a nonseismic building. The licensee is considering mitigating strategies to address the vulnerabilities. These issues have been entered into the licensees corrective action program.

The inspectors determined that, while the licensee has evaluated the fire protection water system to be seismically robust, the licensee does not have policies and procedures in place to protect the system from a seismic event. Specifically, the licensee does not evaluate the fire pump house or fire pumps for seismic concerns with regard to operability and does not take any seismic precautions with regards to temporary equipment such as scaffolding. These issues were entered into the licensees corrective action program for further evaluation.

EXIT MEETING SUMMARY The inspectors presented the inspection results to Mr. M. Perito, Site Vice President Operations, and other members of licensee management at the conclusion of the inspection on April 29, 2011. The inspectors acknowledge they examined licensee proprietary materials during the inspection; all such material has been returned to the licensee.

SUPPLEMENTAL INFORMATION

KEY POINTS OF CONTACT

Licensee

M. Perito, Site Vice President of Operations

J. Browning, General Plant Manager

D. Coulter, Senior Licensing Specialist

K. Ehrharat, Assistant Operation Manager Shift

H. Farris, Assistant Operation Manager Training

K. Higgenbotham, Planning and Scheduling Manager

J. Houston, Maintenance Manager

R. Jackson, Licensing

C. Lewis, Manager, Emergency Preparedness

J. Miller, Operations Manager

C. Perino, Licensing Manager

M. Richey, Director, Nuclear Safety Assurance

P. Salgado, Assistant Operations Manager Support

R. Sumrall, Superintendant, Operations Training

D. Wiles, Engineering Director

R. Wilson, Manager, Quality Assurance